Interest received from Government or an Indian concern: tax inclusion tied to agreement and deductions disallowed for related foreign-currency borrowings. Clauses (a) and (b) are amended to treat receipts as arising only where made 'from Government or an Indian concern in pursuance of an agreement made by the foreign company with Government or with the Indian concern,' and a new clause (c) disallows any deduction for expenditure or allowance in computing income from interest received from Government or an Indian concern on moneys borrowed or debt incurred by them in foreign currency.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Interest received from Government or an Indian concern: tax inclusion tied to agreement and deductions disallowed for related foreign-currency borrowings.
Clauses (a) and (b) are amended to treat receipts as arising only where made "from Government or an Indian concern in pursuance of an agreement made by the foreign company with Government or with the Indian concern," and a new clause (c) disallows any deduction for expenditure or allowance in computing income from interest received from Government or an Indian concern on moneys borrowed or debt incurred by them in foreign currency.
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